A.10.3 AI System Transparency: ISO 42001 Compliance Guide
AI transparency isn't optional—it's a compliance requirement under ISO 42001. Organizations must disclose when AI influences decisions affecting individuals, what data powers those decisions, and how people can request human review. This control builds trust while protecting your organization from regulatory and reputational risk.
What this means
ISO 42001 A.10.3 requires you to be transparent about AI systems that affect individuals or groups. This means: (1) clearly disclosing whenever AI is involved in decision-making processes, (2) explaining what data inputs the AI system uses, (3) providing a clear process for individuals to request human review of AI-assisted decisions, and (4) documenting these transparency measures in your AI governance framework.
How to comply
- 1.Map all AI systems currently in use that impact individuals or groups (hiring, credit decisions, content recommendations, customer segmentation).
- 2.Create clear disclosure statements for each AI system explaining its role, purpose, and data sources in plain language.
- 3.Document the specific data inputs, algorithms, and decision criteria used by each AI system.
- 4.Establish and publish a human review process allowing individuals to request manual review of AI-assisted decisions.
- 5.Train staff on transparency requirements and ensure they can explain AI involvement to customers or affected parties.
- 6.Implement audit logging to track when AI systems make decisions and who requested human reviews.
- 7.Review and update disclosure statements annually as AI systems evolve.
Evidence auditors look for
- AI transparency policy document detailing disclosure requirements for all AI systems
- Customer-facing statements explaining AI use in decision processes (e.g., loan approvals, content filtering)
- Data dictionary showing inputs, sources, and retention periods for each AI system
- Human review request procedures and SLAs for handling appeal requests
- Staff training records on AI transparency communication
- Audit logs demonstrating AI decision tracking and human review request handling
- Privacy notices updated to include AI system disclosures
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
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